Privacy Policy

1. Privacy Policy Overview

This privacy policy (the "Privacy Policy") applies to the website www.Lee.com (the "Website") and refers to the personal data processing activities performed by VF International Sagl ("VF"), who owns and operates the Website. User’s personal data will be processed by VF when user visits the Website and when user interacts with the services and functionalities offered by the Website. The Privacy Policy has been drafted in accordance with the Recommendation n. 2/2001, adopted on May 17, 2001 by Article 29 Data Protection Working Party in relation to the minimum requirements for the collection of data on-line within the European Union and also represents information statement to the data subjects according to section 9 of the Law of December 8, 1992 on Privacy Protection in relation to the Processing of Personal Data, as modified on December 11, 1998, and as supplemented by the Royal Decree of February 13, 2001 (the "Privacy Law"). The Privacy Policy specifies the identity of the data Controller that controls and manages the personal data collected and processed through the Website, specifies what is the personal information collected, the data processing purposes and conditions, the extent of personal data communication to third parties, the data security measures adopted in order to protect and safeguard data and the ways in which the user may verify the processing of data relating to the user and enforce the user’s rights as acknowledged under the Privacy Law.

3. What kind of data are processed; what are the purposes of the data processing

In general, the visit and consultation of the Website does not imply collection and processing of user’s personal data. The processing of user’s personal data that visits and consults the Website is limited to the so-named surfing data, namely the data whose transmission to the Website is implicit in the functioning of the information systems in charge of the managing of the Website and in the use of communications protocols peculiar to the Internet. Surfing data are, for example, the IP addresses or the domain names of the computers employed by the user who connects to the Website and other parameters relating to the type and the information operating system employed by the user. Surfing data, such as these above specified and for example the number of visits, the time spent on the Website are collected and processed by VF exclusively for statistical purposes and in anonymous form in relation to the access and use of the Website for purposes of monitoring the correct functioning of the Website and enhancing the Website functioning and content. Due to the nature itself of surfing data, these data may lead to identification of users if they are associated with data held by third parties; however, VF does not collect surfing data in order to associate them with identified users. Surfing data are deleted after the processing in anonymous form; said data may be used for purposes of assessing possible responsibilities in case of information crimes realized against the Website or through the Website. With the exception of the aforementioned circumstance, VF keeps the user’s surfing data only for the maximum period of time allowed under applicable laws and then makes said data anonymous.

Furthermore, VF collects and processes personal data voluntarily provided by user when user interacts with the Website functionalities and requests the services offered by the Website, for example upon user subscription to the Website; user subscription to newsletter or mailing list; user purchase of products through the Website, which includes all activities relating to the purchase of goods, such as for example delivery of goods, billing issues, returning and, receiving refunds, purchase and use of gift cards and e-gift cards, as applicable, payment related activities, including fraud prevention, and customer support and interaction with our call centre; user participation to promotions and other initiatives realized through the Website such as for example contests and sweepstakes, user request of information to VF or user sending to VF a question, communication or feedback through traditional mail or through the Website and other information.. We will process user’s personal data also to comply with laws, regulations and Community legislation, and to assess and defend a legal right. We may process user’s personal data also when user contacts our customer support which may communicate with user and thus process user’s personal data through e-mail, chat and telephone.. For the processing of your personal data when you make a purchase on our Website, please see our relevant privacy statement. The call centre will also register user’s phone number for purpose of call-back and back-office services in order to provide user with the requested support and information. Marketing, statistical and profiling activities as above specified may also be performed by the call centre, with user’s consent. In some cases, for purposes of internal training, quality control and verification, the call may be recorded and the e-mails may be saved to the extent not prohibited by applicable laws. User will always be informed in advance of the recording of the communication, and user will have the opportunity to object to such recording, save when this is necessary for verification purposes in relation to your purchase or other reasons, as allowed under applicable laws.

With the user’s consent, that is optional, VF may further process user’s personal data for survey purposes; for marketing purposes, that is for sending to user, also through e-mail or other electronic communications means such as SMS, MMS, fax, etc., promotional information and material on products and services of the VF group, on special initiatives on prices and promotions of the VF group and on initiatives such as events, exhibitions and fairs organized by the VF group or to which the VF group takes part; and for profiling purposes. User will always have the opportunity to object, at any time and for free, to the processing of his/her personal data for the sending of promotional information and material; in each communication there will be a specific section in which are specified the conditions (easy to perform and free of charge) of revoking the consent. Personal data that VF collects and processes include name, and contact details such as street address, telephone number, e-mail address and further possible information of an optional nature. In the relevant sections of the Website where data are collected it is published a specific information statement drafted according to the Privacy Law. When requested under the Privacy Law, VF requires the user’s consent before proceeding to processing his/her personal data. Where you have provided us with personal data about another person, (for example when using the function e-mail to a friend, gift card functionalities or other purposes) to the extent permitted by applicable laws you hereby confirm that said communication and further processing by us as set out in this Privacy Policy complies with applicable privacy laws, so for example you should inform said person and as requested obtain his/her consent to the processing of his/her personal for the purposes set out in this Privacy Policy.

4. Place where the data are stored

Personal data collected through the Website will be processed by VF; the data Processor provides for VF hosting services for the Website and related database, as well as for the activities of managing the customer support and the call centre. The updated list of Processors and addresses of data communications is at your disposal at VF. Personal data are processed only through specifically authorized staff designated to access and process the data, including staff designated for performance of non-routine maintenance operations of the Website. User is invited to check the section of this Privacy Policy relating to Extent of personal data communication. All Processors are acting on behalf and under the instructions of VF.

5. Cookies

Cookies are small data files stored on the hard disk of the users’ computer. The Website deploys cookies for specific and limited purposes, notably in order to offer to user an easier surfing on the Website, to make login easier (for example by remembering user’s username and password), for internal security purposes, system administration, trend analysis. The cookies deployed by VF cannot be used to run programs on the user’s computer or to download viruses on the same, and they do not allow VF any kind of control on the user’s computer. VF does not use cookies to access information stored on the user’s computer, to store information on the same and to monitor user’s operations. This section of the Privacy Policy relating to Cookies applies to cookies and any other tracking technology that may be used by VF and applies to the computer of the user as well as any other device employed by user to connect to the Website. The so called ‘session cookies’ are stored in a temporary memory and are deleted when user closes the browser. Session cookies do not collect any information from the user’s computer. Cookies that are used upon subscription of the user to the Website collect user personal information that allows VF to recognize the user in case of following visit to the Website and they are used in order to make easier the surfing of the Website and the login procedure, allow VF understand what are the sections of the Website that user is most interested in, in order to offer to user a personalized visit of the Website and of the information thereon published, and for security and managing purposes as above specified. The Website may contain links to other websites. VF does not have any type of access or control on cookies, web bacons and other user tracking technologies that are present on websites of third parties that are accessible from the Website, on the availability and on any content or material contained in, or obtained through, any such websites, and on the conditions of processing of user’s personal data by said third parties’ websites, and hereby expressly disclaims any relevant liability. VF invites user to consult the privacy policy of third parties’ websites that user accesses from the Website in order to be informed on the conditions of collection and processing of user’s personal data, since this Privacy Policy only applies to the Website as above defined. Most web browsers automatically accept cookies, but user can usually change the web browser to disable this function. The section "Help" of the toolbar placed on the majority of browsers explains how to avoid receipt by browser of cookies, web bacons and other technologies employed to track users, how to obtain from browser notice of receipt of the referenced technologies or how to disable them completely. Disabling of cookies may limit the possibility to use the Website and may prevent user from fully benefiting of the Website functionalities and services.

6. Conditions and features of the personal data processing

Personal data collected by VF are mainly processed through electronic and automated means but also without the same (paper processing), under procedures and logics that comply with the data processing purposes as herein specified. Personal data of user are processed according to applicable privacy laws, including security and confidentiality issues, and are kept only for the time strictly functional to achieve the specific data processing purpose from time to time pursued and according to applicable laws.

7. Security and quality of personal data

VF is committed to protect security of the user’s personal data. Personal data are processed by VF in compliance with the security provisions as set forth by applicable laws in order to prevent loss and destruction, even accidental, of data, unauthorized access to data, unlawful or unfair use of data. Moreover, information systems and software programs are configured so that personal and identification data are used only when necessary to achieve the specific processing purpose from time to time sought.

VF deploys a variety of advanced security technologies and procedures to help protection of user’s personal data against the risks above outlined. For example, personal data provided by user are stored on secured servers placed in controlled locations. Moreover, for the transmission of some data through the Internet are deployed encryption techniques such as the Secure Socket Layer (SSL) protocol. User may help VF to update and maintain accuracy of the personal data provided by user to VF by notifying VF of any amendment relating to user’s address, title, telephone number or electronic mail (e-mail) address. Registered user may perform the foregoing on-line following the instructions reported on relevant user’s profile pages of the Website.

8. Extent of personal data communication

VF communicates user’s personal data within the limits and under the circumstances specified in this Privacy Policy and in the information statement published on the Website in the sections where data are collected, in any case in full compliance with the consent given by the user upon collection of data, when required by the Privacy Law. User personal data will be accessible within VF organization by the internal and external personnel that need to access them because of their duties in relation to the processing purposes herein specified, and by our Processors, as applicable. The updated list of Processors and of the subjects to which data may be communicated will remain at user disposal free of charge upon request at VF.

User personal data may be communicated to institutions, authorities, public entities, banks and financial institutions, professionals, independent consultants, also in associate form, business partners and third party service providers to which VF may revert to for performance of professional, technical and organizational services functional to the managing of the Website and the activities therein performed, such as for example the sales of goods and related activities, the managing of functionalities offered by the Website and of the initiatives and services that user may subscribe to and require through the Website, and for services strictly functional to achievement of the other processing purposes herein specified. For purposes functional to the managing of the Website and related activities, user’s personal data may be also communicated to third party service providers supporting the Website and the relevant e-com platform, that will process them according to applicable privacy laws for the purposes above specified. With specific reference to the purchase of goods, data will be processed by the data Processor under the direction of VF and in accordance with applicable privacy laws, for the following purposes: billing issues, dispatch of goods, returning and exchanging of goods, receiving refunds, purchase and use of gift cards and e-gift cards as applicable, payment related activities, including fraud prevention. These service providers and the data Processor are bound by contract obligations so that they will implement adequate security measures to protect security and confidentiality of user’s personal data and credit card information.

The third parties receiving user’s personal data as above specified will process data as data Processors according to applicable data protection laws and for the same purposes above specified. Personal data may also be communicated to third parties in case of mergers, acquisitions, transfer of any of our assets, products, websites or operations. These third parties will be provided only with the information necessary to performance of their respective functions; they agree to use the information received only for the processing purposes above specified, to keep it confidential and secure and to comply with applicable law and the instructions received by VF. Except for the foregoing, user’s personal data will not be shared with third parties, natural persons or legal entities, that are unrelated to, or that do not perform a business, professional or technical function for VF. User’s personal data may further be communicated to whoever is the legitimate addressee of communications as provided by applicable laws and regulations, thus for example in case of judicial processes, request by competent courts and authorities or other legal obligation, to protect and defend the rights and property of VF and the Website. User’s personal data will not be communicated to third parties other than VF companies for their own marketing purposes and will under no circumstance be spread.

9. Providing of personal data

Except for the foregoing description in relation to the surfing data, providing of personal data by user is necessary for performance of the services and functionalities offered by the Website and required by user, such as the user subscription to the Website, to newsletters or mailing lists, the managing of the user purchase of products through the Website and related activities, the managing of user participation to promotions and other initiatives realized through the Website such as for example contests and sweepstakes, replying to and managing of user’s request of information, questions, communication or feedback to VF, and other information sent by the user. Providing of user’s personal data for the activities necessary to comply with applicable legislation is mandatory. In the above referenced circumstances, denial of providing personal data by user would make it impossible for VF to comply with contractual obligations or to provide user with the requested services, products or information as above specified.

Providing of data by user for the survey purposes, the marketing purposes, and the profiling purposes as above specified is optional; denial of providing personal data by user in said circumstances will have no consequences on compliance by VF with its contractual obligations and on the providing user with the services, products or information requested as above specified.

10. User’s privacy rights

User is entitled at any moment to enforce the rights as provided under Art. 10 of the Privacy Law or other applicable privacy law, as the case may be, including but not limited to the right to obtain at any moment confirmation that user’s personal data exist or do not exist, verify their content, origin and accuracy, ask for their integration, updating, amendment, deletion, and user may oppose for legitimate reason the data processing (including objecting, at any time and for free, to the processing of his personal data for direct marketing purposes).

For any query or request relating to the personal data processing by VF and to enforce the rights under the Privacy Law, user may contact Hermes NexTec GmbH, acting as data Processor of VF, as follows: "Hermes NexTec GmbH – LEE & Lee E-commerce Customer Service", +44 (0) 800 0855622; or by sending an e-mail through the proper form provided at the following link: Contact Us.

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This Privacy Policy is subject to updating and amendment by VF. The version published on the Website is the version actually in force. If VF changes this Privacy Policy, VF will notify user of such changes by posting a link on the home page of the Website to the amended privacy policy that reads "Newly Revised Privacy Policy". VF invites user to periodically review the Privacy Policy in order to be informed of any relevant change. The Effective Date of this Privacy Policy is: August 04, 2010